Jerry and Patricia A. Dixon, et al. - Page 9

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          DuFresnes, Owenses, and Hongsermeiers, Izen remained counsel of             
          record for the Youngs, the only other remaining test case                   
               In January and February 2001, the Hongsermeiers and 112                
          nontest case petitioners (hereafter, the group of 112) made                 
          contributions to the Defense Fund (all but two in the amount of             
          $1,500) totaling $168,600 in connection with the hiring of Minns.           
          In addition, from January 2001 through November 2001 (the last              
          full month during which the steering committee recognized Minns             
          as the Fund’s counsel), the Hongsermeiers and 106 members of the            
          group of 112 made smaller contributions to the Defense Fund                 
          totaling $99,600.  Thus, total contributions to the Defense Fund            
          by the Hongsermeiers and the group of 112 from January 2001                 
          through November 2001 amounted to $268,200.  The Fund paid the              
          aforementioned fees of $110,000 and $75,000 to Minns and                    
          Lawfinders, respectively, in early 2001.8                                   
               The steering committee became dissatisfied with Minns, and             
          by letter dated December 7, 2001, the Defense Fund formally                 
          requested Porter & Hedges, L.L.P. (Porter & Hedges) to take over            
          the appeals and to represent the Fund in “the anticipated                   
          litigation involving our former attorney in this matter, Michael            
          Minns.”  The ensuing engagement letter confirms that Porter &               

          8 The Fund paid other amounts under the Minns agreement,                    
          including a $20,000 fee to an accounting firm, for which the                
          Hongsermeiers do not seek recovery.                                         

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